T2 Adjustment Case Studies

6 T2 Adjustment tax and accounting engagements in full — what the client came to us with, what we did, and what it was worth. Each one is specific to t2 adjustment work, not a general example.

Case Study 1 · Missed incentive claimed

$119,000 Credit Claim Filed And Accepted Without Adjustment — Taxpayer with Eight Years, Saskatoon

Client: A taxpayer with eight years of unfiled returns  ·  Where: Saskatoon, Saskatchewan  ·  Engagement: 3 weeks, fixed fee

Claim value$119,000
AcceptedWithout adjustment
RepeatableAnnually

The situation

A taxpayer with eight years of unfiled returns in Saskatoon, Saskatchewan assumed the credits did not apply to a business its size. A net-worth assessment built on unexplained deposits that were actually loan proceeds meant they had applied all along.

What we did

We identified the qualifying activity, built the documentation to support it, and assembled the contemporaneous records, filed a structured response to each proposed adjustment with the supporting documents indexed, and had the proposal withdrawn.

The result

$119,000 recovered. Because the eligibility analysis is on file, the same claim can be repeated each year with a fraction of the effort.

Case Study 2 · Records and systems rebuilt

Month-End Close Cut From 12 Weeks To 8 Days — Taxpayer with Frozen Bank, Barrie

Client: A taxpayer with frozen bank accounts  ·  Where: Barrie, Ontario  ·  Engagement: 3 weeks, fixed fee

Close time before12 weeks
Close time after8 days
Year-endReview, not rebuild

The situation

The accounting file at a taxpayer with frozen bank accounts in Barrie, Ontario was built on an objection deadline that had passed with no extension applied for. The year-end had taken 12 weeks each of the last three years.

What we did

We traced each unexplained deposit to its source — loans, transfers between accounts, an insurance settlement — and reduced the net-worth assessment accordingly and moved the reconciliations into the monthly cycle, so the year-end stopped being a rebuild.

The result

The file reconciles. Month-end closes in 8 days instead of 12 weeks, and the year-end is a review rather than a reconstruction.

Case Study 3 · Sale and succession

$480,000 Sheltered By The Lifetime Capital Gains Exemption — Corporation Under a GST/HST, Winnipeg

Client: A corporation under a GST/HST review  ·  Where: Winnipeg, Manitoba  ·  Engagement: 11 weeks, fixed fee

Gain sheltered$480,000
ClosingOn schedule
Share qualificationMet

The situation

A corporation under a GST/HST review in Winnipeg, Manitoba had an offer on the table and 32 months to close. The shares did not qualify for the capital gains exemption, and no valuation on file to support the price the parties had agreed was part of the reason.

What we did

We purified the corporation so the shares met the qualifying tests, then brought every outstanding return current, then negotiated a payment arrangement that stopped the collections action well ahead of the closing date.

The result

The sale closed on schedule with $480,000 sheltered by the lifetime capital gains exemption across the shareholders.

Case Study 4 · Cash and remittance control

Remittance Schedule Corrected, $147,000 Refunded — Family Business Under a, Red Deer

Client: A family business under a related-party review  ·  Where: Red Deer, Alberta  ·  Engagement: 6 weeks, fixed fee

Overpayment refunded$147,000
Late remittances sinceZero
ScheduleAutomated

The situation

Remittances at a family business under a related-party review in Red Deer, Alberta were consistently late by a few days, which was enough to trigger penalties every quarter. Behind it sat six years of unfiled corporate and personal returns and an active collections file.

What we did

We filed the disclosure through the Voluntary Disclosures Program before contact, which removed the gross-negligence penalty entirely, then moved the remittance dates into a scheduled process rather than a monthly decision.

The result

Penalties stopped from the following remittance onwards, and $147,000 of overpaid instalments was refunded.

Case Study 5 · Backlog brought current

$41,000 Of Arbitrary Assessments Vacated After 4 Years — Business Owner with a, Vancouver

Client: A business owner with a director liability assessment  ·  Where: Vancouver, British Columbia  ·  Engagement: 9 weeks, fixed fee

Arbitrary tax vacated$41,000
Years brought current4
Account statusCurrent

The situation

4 years of unfiled returns had turned into notional assessments at a business owner with a director liability assessment in Vancouver, British Columbia, with a net-worth assessment built on unexplained deposits that were actually loan proceeds underneath. Collections had already started.

What we did

We assembled the contemporaneous records, filed a structured response to each proposed adjustment with the supporting documents indexed, and had the proposal withdrawn, then filed every outstanding year in chronological order so the CRA could vacate the notional assessments cleanly.

The result

All 4 years were accepted as filed. $41,000 of arbitrarily assessed tax was vacated, collections action stopped, and the account is current for the first time in 4 years.

Case Study 6 · Planning that cut the bill

$49,000 Saved By Correcting What Prior Filings Had Missed — Importer Under a Customs, Burnaby

Client: An importer under a customs and GST audit  ·  Where: Burnaby, British Columbia  ·  Engagement: 7 weeks, fixed fee

Saving identified$49,000
RecurringYes
Positions documentedAll

The situation

An importer under a customs and GST audit in Burnaby, British Columbia asked for a second opinion on t2 adjustment after three years of rising tax. The review found a director liability assessment for a corporation that had already stopped operating.

What we did

We built the comparison first — current structure against two alternatives — and then traced each unexplained deposit to its source — loans, transfers between accounts, an insurance settlement — and reduced the net-worth assessment accordingly.

The result

First-year saving of $49,000, with the same benefit recurring. Every position taken is documented and supported in the file.

Reviewed for the 2025 tax year by Udit Gupta, Certified Tax Accountant. Figures describe representative engagements of this type; outcomes depend on your own facts. Client names and identifying details are omitted for confidentiality.

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